The Medicaid eligibility reforms issued as part of the Working Families Tax Cut legislation—also known as the One Big Beautiful Bill Act—mean that by January 1, 2027, states will be required to enforce work requirements for Medicaid claimants. The Centers for Medicare and Medicaid Services (CMS) issued guidance in early December, leaving states just over 12 months to implement major system changes. Some states may be able to leverage work requirement tracking from SNAP programs, while others will need to start from scratch. Whichever approach they take, states will need a flexible solution that can be stood up quickly and integrate with existing systems. Here are four key considerations for meeting the Medicaid work requirements deadline.
1. Interoperability
The short timeline for implementing work requirements is pressuring states to opt for the fastest available option, especially considering the lengthy procurement processes project implementations often require. In most cases, the remaining time until implementation is not enough to fully upgrade their Medicaid systems. In these situations, Cynthia Perkins, Director of Solutions, Health and Human Services at TCS – Tata Consultancy Services, recommends prioritizing interoperability with a solution capable of integrating with both legacy technology and more modern upgrades and additions. Low-code/No-code solutions that are designed to integrate with existing systems are becoming more common and more accessible,” she shared. “Since they don’t need to be built from the ground up, these can be a great way to stand something up quickly and start putting technology to work for constituents and caseworkers.”
2. Automation & Data Integration
Many state programs, such as SNAP and TANF, already enforce work requirements for their recipients. Adding another program to the list doesn’t need to place additional burden on constituents. Perkins explained that automation and data integration between agencies and programs can simplify eligibility tracking for both case workers and recipients. “If someone is already working their 80 hours and proving that for one program, it’s ideal for Medicaid programs to bring in that information automatically, so they don’t lose people who are doing the right things,” she said. Perkins also sees an opportunity for recipients who are exempt from work requirements. In the case of chronic or permanent disability, she added, that designation is not going to change. “That component should be automated as well so that neither the case worker nor the claimant spend time ‘re-proving’ their disability.”
3. Integration with Workforce
After the new work requirements go into effect, constituents who were previously covered by Medicaid will no longer to be eligible because of unemployment or working too few hours. Perkins presented a creative option for states to help this population: “If your program is already connected to workforce programs to verify job status, why not help people find a job as well?” Data integration between programs can be used to identify claimants who are no longer eligible for Medicaid but are eligible for programs such as a state labor exchange. Perkins added that searching for employment can also help claimants meet work requirements, helping to bring constituents into compliance even before they sign a job offer.
4. AI to Help Ensure Accuracy and Efficacy
One major concern surrounding the implementation deadline is that rushing to stand up systems creates ample opportunities for errors that could result in unnecessary coverage losses. The new requirements are likely to increase workloads for state staff who will now have to verify every claimant’s work status each month. The AI that is now often embedded into No-code/Low-code solutions can be employed to:
- Identify the cases that are most likely to lose eligibility
- Sort cases and appeals to be dealt with more efficiently by a case worker
- Collate data from myriad sources for case workers to review
“Everything an eligibility case worker does takes time and precision,” Perkins said. “So, the more you streamline the processing of these claims, the more accurate they can be.” The AI use cases states are already exploring can help support over-burdened and under-resourced case workers through the critical early period of Medicaid eligibility requirements.
Conclusion
Medicaid eligibility and work requirements will likely evolve as the deadline for implementation approaches, so maximizing flexibility in any solution will be essential. These four key considerations will help states form a strategic approach to meeting the 2027 launch date while leaving room to adapt to any changes in legislation or constituent needs.
